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There is an interesting article on whether the US or Europe has been more precautionary published by Hammitt, Wiener, et al. in Risk Analysis, 25: 1215 (October 2005):

Abstract for:

Precautionary Regulation in Europe and the United States: A Quantitative Comparison

Much
attention has been addressed to the question of whether Europe or the
United States adopts a more precautionary stance to the regulation of
potential environmental, health, and safety risks. Some commentators
suggest that Europe is more risk-averse and precautionary, whereas the
United States is seen as more risk-taking and optimistic about the
prospects for new technology. Others suggest that the United States is
more precautionary because its regulatory process is more legalistic
and adversarial, while Europe is more lax and corporatist in its
regulations. The flip-flop hypothesis claims that the United States was
more precautionary than Europe in the 1970s and early 1980s, and that
Europe has become more precautionary since then. We examine the levels
and trends in regulation of environmental, health, and safety risks
since 1970. Unlike previous research, which has studied only a small
set of prominent cases selected nonrandomly, we develop a comprehensive
list of almost 3,000 risks and code the relative stringency of
regulation in Europe and the United States for each of 100 risks
randomly selected from that list for each year from 1970 through 2004.
Our results suggest that: (a) averaging over risks, there is no
significant difference in relative precaution over the period, (b)
weakly consistent with the flip-flop hypothesis, there is some evidence
of a modest shift toward greater relative precaution of European
regulation since about 1990, although (c) there is a diversity of
trends across risks, of which the most common is no change in relative
precaution (including cases where Europe and the United States are
equally precautionary and where Europe or the United States has been
consistently more precautionary). The overall finding is of a mixed and
diverse pattern of relative transatlantic precaution over the period.